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Bring Efficiency and Sanity Back to the Operational Transfer Pricing Process!

Does your company spend too much time on Operational Transfer Pricing? Is the process efficient and transparent? Or is too much time spent in low-value activity like gathering data and manipulating it in spreadsheets. If you are like most companies, the transfer pricing process has a lot of room for improvement. With the ever increasing scrutiny on corporate taxation, many companies are looking to improve the transfer process to ensure it has all the proper controls and efficiency necessary for today’s multinational companies.

Marc Seewald, Senior Director of Product Management for EPM Applications specializing in the tax domain and Product Manager for Oracle Hyperion Tax Provisioning, and Bart Stoehr, Senior Director of Product Strategy for Oracle Hyperion Profitability and Cost Management joined me for a discussion/podcast on this interesting subject.

So what exactly is “Operational transfer pricing”? Marc defined it this way. “Transfer pricing is a profit allocation methodology required to be used by multinational corporations. Specifically, the ultimate goal of transfer pricing is to ensure that intercompany allocations result in true economic profitability by legal entity. According to Marc, in today’s global economy, profitability can be significantly impacted by goods and services exchanged between the related divisions within a single multinational company.

Today, most companies manage the operational transfer pricing in a very manual process – typically relying heavily on Excel or custom-built solutions such as MS Access. A significant amount of time is spent on collecting, manipulating, and aggregating data. However, the collection of the data to support the intercompany allocations is only half of the battle. Once the data has been properly collected, companies then need to apply transfer pricing assumptions. This, too, likely takes place in Excel. Many companies spend weeks, or even months, preparing for a single transfer pricing calculation.

The effort associated with a manual transfer pricing process is not the only problem. Excel-based processes often lack the proper controls and transparency necessary for such material financial reporting activity. This can result in material mistakes during the reporting process. Additionally, the lack of transparency can cause headaches later on during audits.

What are the repercussions of improper operational transfer pricing? How important is it? Because of its potential impact on taxes paid by a company, revenue agencies like the IRS, and international regulatory bodies like the Organization for Economic Cooperation and Development (OECD) are pushing to reform and clarify reporting for tax transfer pricing. Most recently the OECD announced an “Action Plan for Base Erosion and Profit Shifting”. As Marc explained, the times are changing and companies need to be responsive to this issue. It’s imperative that companies have a clear and auditable operational transfer pricing process that enables them to clearly document intercompany profitability and avoid steep penalties and bad publicity.

Transparency and efficiency are what is needed when it comes to the operational transfer pricing process. Bart explained that transfer pricing is driving a deeper inspection of profit recognition specifically focused on the tax element of profit. However, allocations needed to support tax profitability are nearly identical in process to allocations taking place in other parts of the finance organization. For example, the methods and processes necessary to arrive at tax profitability by legal entity are no different than those used to arrive at fully loaded profitability for a product line. In fact, there is a great opportunity for alignment across these two different functions.

So it seems that operational transfer pricing should be reflected in profitability in general. Bart agreed and told us more about some of the critical sub-processes within the Oracle solution for operational transfer pricing. “First, there is a ton of data preparation, enrichment and pre-allocation data analysis that is managed in the Oracle Hyperion solution. This serves as the “data staging” to the next, critical sub-processes. From here, we leverage the Oracle EPM platform’s ability to re-use dimensions and legal entity driver data and financial data with Oracle Hyperion Profitability and Cost Management (HPCM). Within HPCM, we manage the driver data, define the legal entity to legal entity allocation rules (like cost plus), and have the option to test out multiple, simultaneous operational transfer pricing what-if scenarios. Once processed, a tax expert can evaluate the effectiveness of any one scenario result versus another via a variance analysis configured with HPCM’s pre-packaged reporting capability known as Oracle Hyperion SmartView for Office.”

Further, Bart explained that the ability to visibly demonstrate how a cost or revenue has been allocated is really helpful and auditable. “HPCM’s Traceability Maps are that visual representation of all allocation flows that have been executed and is the operational transfer analyst’s best friend in maintaining clear documentation for operational transfer pricing audits. Simply click and drill as you inspect the chain of allocation definitions and results. Once final, the post-allocated tax data can be compared to the GL to create invoices and journal entries for posting to your GL system of choice. Of course, there is a framework for overall governance of the journal entries, allocation percentages, and reporting to include necessary approvals.”

Lastly, Marc explained that the key value in using HPCM for operational transfer pricing is that it keeps everything in alignment in one single place. Specifically, Oracle Hyperion effectively becomes the single book of record for the GAAP, management, and the tax set of books. There are many benefits to having one source of the truth. These include EFFICIENCY, CONTROLS and TRANSPARENCY.

So, is there room for improvement? Why not automate the operational transfer pricing process!

To listen to the entire podcast, click here.To learn more about Oracle Hyperion Profitability and Cost Management (HPCM), click here.